Linkenauger v. South Central Regional Jail and Correctional Facility Authority, 2:19-cv-00718

Plaintiff John S. Linkenauger II alleges he worked as a dishwasher/cook at South Central Regional Jail (SCRJ) for 22 days in June 2019 and was not paid for that work.
After release and upon later reincarceration, Linkenauger claims he sought payment; a cook employed by Trinity (private food-service contractor) named Phil denied knowing him or that he worked there.
Linkenauger sued multiple defendants (SCRJ Authority, West Virginia Regional Jails, Trinity, and Phil) seeking $7,500 for pain and suffering, lost wages, and other relief, and filed an application to proceed in forma pauperis (IFP).
The Magistrate Judge screened the complaint under 28 U.S.C. §§ 1915(e) and 1915A and recommended denial of the IFP application and dismissal for failure to state a claim.
The court concluded the federal Constitution does not guarantee compensation for inmate labor; state agencies are not "persons" under § 1983; a private contractor is only liable under § 1983 for deprivations caused by its policy or custom; and any state-law defamation claim lacks federal jurisdiction because the amount in controversy is below $75,000.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether being required to work without pay violates the Constitution / supports a § 1983 claim	Linkenauger asserts entitlement to payment for kitchen work	Constitution does not guarantee inmate compensation; forced unpaid work is not unconstitutional	Dismissed: no constitutional right to pay for inmate labor; § 1983 claim fails
Whether state jail authorities are proper § 1983 defendants	Linkenauger sued those agencies	State agencies and officials in official capacity are not “persons” under § 1983	Dismissed as to state agencies: not proper § 1983 defendants
Whether Trinity (private contractor) is liable under § 1983	Linkenauger challenges Trinity/its employee for denying his work and pay	Private entity liable under § 1983 only if an official policy or custom caused the deprivation	Dismissed as to Trinity: plaintiff did not plead a policy/custom linking Trinity to violation
Whether federal courts have jurisdiction over state-law defamation claim	Linkenauger seeks $7,500 for defamation	Amount in controversy is below $75,000 required for diversity jurisdiction	No federal jurisdiction over defamation claim; claim not viable in federal court

Eriline Co. S.A. v. Johnson, 440 F.3d 648 (4th Cir. 2006) (district courts must screen IFP complaints for lack of arguable legal or factual basis)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard; courts disregard conclusory allegations)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
Will v. Michigan Dep't of State Police, 491 U.S. 58 (1989) (States and state agencies are not "persons" under § 1983)
West v. Atkins, 487 U.S. 42 (1988) (private actors can act under color of state law for § 1983 purposes)
Austin v. Paramount Parks, Inc., 195 F.3d 715 (4th Cir. 1999) (private corporation liable under § 1983 only when an official policy or custom causes the deprivation)
Loving v. Johnson, 455 F.3d 562 (5th Cir. 2006) (compelling inmate work without pay does not violate the Constitution)
Newell v. Davis, 563 F.2d 123 (4th Cir. 1977) (Thirteenth Amendment claim for inmate labor without pay was rejected)